Commonwealth v. Stauffer

42 Pa. D. & C.5th 160
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedOctober 21, 2014
DocketNo. 176 of 2014, CR
StatusPublished

This text of 42 Pa. D. & C.5th 160 (Commonwealth v. Stauffer) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Stauffer, 42 Pa. D. & C.5th 160 (Pa. Super. Ct. 2014).

Opinion

MOTTO, P.J.,

Before the court for disposition is the petition for writ of habeas corpus filed on behalf of the defendant, Justin Stauffer, which contends that the Commonwealth failed to establish a prima facie case as to each of the charges filed against the defendant. The defendant contends that because the victim testified that on the date of the alleged rape, she initially consented to engage in unprotected sexual intercourse with defendant, including the act of penetration, there is insufficient evidence to establish a prima case for each of the charges. The dispositive issue is whether the Commonwealth has net its burden of providing evidence to support a prima facie case for rape by forcible compulsion, sexual assault and indecent assault, where the victim withdrew her consent after penetration, and the continuation of intercourse was [162]*162accompanied by force and without consent.

This case arises from an alleged sexual assault that occurred at the defendant’s residence with a female victim, Gavynne Hehman. The victim testified at the preliminary hearing that she had been in a relationship with the defendant since April 2013. According to the victim’s testimony, on the day of this incident the defendant had picked her up at her house and took her to his residence at 946 cleland Mill Road in North Beaver Township, Lawrence County. The victim stated that she did not know the exact date of the assault, but was sure that it was a few days before Halloween in October 2013 The victim testified that once they arrived at the defendant’s residence they went to the defendant’s bedroom and sat down on the bed together. The defendant indicated that he wanted to have sex with the victim and she refused and said that she was not on birth control and she did not want to become pregnant. According to her testimony, the defendant kept asking her to have sex until she finally relented and said she would, but only if the defendant wore a condom. The defendant stated that he did not like condoms and would not wear one. After some persuasion by the defendant, however, the victim agreed to sexual intercourse with the defendant on the condition that he would stop and withdraw prior to ejaculation. According to the victim, the defendant agreed to withdraw before ejaculation. The victim stated that during the intercourse, the defendant stated that he was about to ejaculate. At this point, the victim told him to stop and reminded him that had agreed to withdraw. According to the victim’s testimony, when she told the defendant to stop and withdraw he refused and grabbed her arms and wrists and held them behind her back with one hand and placed his other hand on her upper back and forced her down onto the bed. The victim stated that she was bent over the bed with the victim [163]*163behind her unable to move because he was holding her down. According to her testimony, the defendant stated “No. I’m not going to stop.” and that he was going to ejaculate inside her whether she wanted him to or not. The victim tried to move and pull away from the defendant but the defendant held her down and she was unable to move. The victim testified that the defendant held her down and continued the intercourse to the point of ejaculating inside of her and then released her. The victim testified that after the defendant released her she got up and got dressed and walked upstairs and spoke with the defendant’s family, but that she did not tell them what had happened. The victim testified that when the defendant drove her home later that evening she asked him why he held her down when she did not want to continue having intercourse and he replied that that it was not a big deal and not to worry about it because she was not going to get pregnant. The victim stated the defendant told her not to tell anyone about what happened.

The victim further testified that she found out she was pregnant shortly after the assault and told her parents that she was pregnant in November 2013, right before Thanksgiving. She stated that she did not inform her parents about the assault at that time because she was still in a relationship with the defendant — and was afraid that he would harm her if she told anyone. According to the victim’s testimony on cross examination, after this incident she continued having consensual sexual intercourse with the defendant up until the time she ended their relationship in December 2013. The victim stated that her relationship with the defendant ended around Christmas when she first told her parents about the sexual assault. The victim testified that after she ended her relationship with the defendant he continued to try and contact her by calling her and showing up at her house.

[164]*164On January 8,2014 the victim contacted the state police and was interviewed by Pennsylvania State Trooper Harry Gustafson, Jr. about the sexual assault. Based on victim’s statement, the defendant was charged with rape by forcible compulsion (18 Pa.C.S. §3121(a)(l)), sexual assault (18 Pa.C.S. §3124.1), unlawful restraint (18 Pa.C.S. §2902(a) (1)), and indecent assault (18 Pa.C.S. §3126(a)(2)). A preliminary hearing was held on February 20, 2014 before Magisterial District Judge Jerry Cartwright. At the conclusion of the hearing, District Judge Cartwright bound all the charges against the defendant over to this court except unlawful restraint. The defendant filed a petition for writ of habeas corpus on May 9, 2014 challenging the sufficiency of the commonwealth’s evidence. At the habeas corpus hearing, the Commonwealth presented the notes of testimony of the preliminary hearing. No additional evidence was offered by either party.

Filing a petition for a writ of habeas corpus is the appropriate method by which a defendant may challenge a pre-trial finding that the Commonwealth has presented sufficient evidence to establish a prima facie case. Commonwealth v. Karlson, 614 A.2d 249 (Pa. Super. 1996); see also Commonwealth v. McBride, 528 Pa. 153, 595 A.2d 589 (1995); Commonwealth v. Carmody, 199 A.2d 143 (Pa. Super. 2002). In evaluating an accused’s entitlement to pre-trial habeas corpus relief, a trial court must determine whether there is sufficient evidence to make out a prima facie case that the defendant committed the crime with which he or she is charged. Comm v. Hock, 556 Pa. 409, 728 A.2d 943 (1999). The Commonwealth must satisfy this evidentiary burden by presenting evidence that established a crime was committed and that there is a probability that the Defendant committed the crime. Commonwealth v. Fox, 422 Pa. Super. 225, 619 A.2d 327 (1993). The Commonwealth establishes & prima facie case [165]*165by offering some proof to establish each material element of the offense as charged. Commonwealth v. Owen, 397 Pa. Super. 507, 580 A.2d 412 (1990). The Commonwealth is not required to prove this by the “beyond a reasonable doubt” standard; however, the Commonwealth must satisfy a standard of “sufficient probable cause” that the accused has committed the offense. Commonwealth v. Prosdocimo, 479 A.2d 1073 (Pa. Super. 1994).

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Related

State v. Way
254 S.E.2d 760 (Supreme Court of North Carolina, 1979)
Commonwealth v. Hock
728 A.2d 943 (Supreme Court of Pennsylvania, 1999)
Battle v. State
414 A.2d 1266 (Court of Appeals of Maryland, 1980)
Commonwealth v. Owen
580 A.2d 412 (Supreme Court of Pennsylvania, 1990)
Commonwealth v. Marti
779 A.2d 1177 (Superior Court of Pennsylvania, 2001)
State v. Robinson
496 A.2d 1067 (Supreme Judicial Court of Maine, 1985)
Baby v. State
916 A.2d 410 (Court of Special Appeals of Maryland, 2007)
Commonwealth v. McBride
595 A.2d 589 (Supreme Court of Pennsylvania, 1991)
Commonwealth v. Fox
619 A.2d 327 (Superior Court of Pennsylvania, 1993)
State v. Baby
946 A.2d 463 (Court of Appeals of Maryland, 2008)
Commonwealth v. Prosdocimo
479 A.2d 1073 (Supreme Court of Pennsylvania, 1984)
State v. Bunyard
133 P.3d 14 (Supreme Court of Kansas, 2006)
State v. Siering
644 A.2d 958 (Connecticut Appellate Court, 1994)

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Bluebook (online)
42 Pa. D. & C.5th 160, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-stauffer-pactcompllawren-2014.